Five questions to test any herbal claim, from a $23,000 COVID plan that landed in court

Key takeaways

• The Federal Trade Commission says every health claim, including soft “supports” wording, needs competent and reliable scientific evidence, and a “clinically proven” claim needs the level of proof it brags about.
• In February 2026, the FTC mailed refund checks to people who bought herbal “plans of care” that the agency says were falsely pitched against COVID-19, cancer and Parkinson’s disease, including a $23,000 COVID-19 plan.
• By early 2022, the FTC had sent COVID-19 warning letters to more than 400 companies and individuals, and the products included botanicals, herbal remedies and teas.
• FTC guidance says a German monograph, an “ancient” pedigree or a study of one ingredient doesn’t prove that a particular bottle works.
• Score any claim with five questions, report false ads at ReportFraud.ftc.gov, and report harm to FDA’s MedWatch program.

For $23,000, a company called Golden Sunrise Nutraceutical sold a COVID-19 treatment plan, according to the Federal Trade Commission (FTC). The agency alleged that the company’s medical director helped advertise it as a “scientifically proven way to treat COVID-19”².

The company sold these “plans of care” from 2017 to 2020, and the FTC says the products were mostly herbs and spices³. The FTC also alleged that the medical director used false or unproven claims that other plans could cure cancer and Parkinson’s disease².

The case took years to close. The medical director settled in June 2021; the order barred similar unsupported claims and required him to pay $103,420². In September 2025, a federal court in California issued a summary decision in the FTC’s favor against the company and the remaining defendants, barring them from unsupported health claims². In February 2026, the agency mailed 578 checks totaling more than $40,700 to buyers².

Most herbal products aren’t sold with promises like these. But phrases like it show up in everyday marketing too, next to “clinically tested,” “supports immunity,” “doctor recommended” and “ancient formula.”

Each phrase makes a different promise, and federal rules say how much proof each one needs. Below, we look at how to read the dialect and score a claim in a few minutes.

The law asks for proof that matches the promise

Two agencies share the job. Under federal law, a supplement sold to treat or prevent a disease counts as an unapproved drug, which puts it in the Food and Drug Administration’s (FDA) territory⁷. Our article on “supports” versus “cures” explains that line. The FTC polices health advertising, working with the FDA¹⁰.

In December 2022, the FTC issued its Health Products Compliance Guidance, replacing a 1998 advertising guide for supplements¹. Its core rule: health claims need “competent and reliable scientific evidence”¹. That means studies run and judged objectively by qualified experts. For health benefits, randomized controlled trials, where people are assigned by chance to the product or a comparison, are the most reliable kind¹.

Three parts of the guidance matter most for shoppers.

• Soft words need real proof. Claims about supporting a body function need the same backing as any other health claim¹. Pictures count too. In one FTC example, a made-up herbal product called “Cold Away” talks about immune support for winter, shows people sneezing and coughing, and so promises to prevent colds¹.
• Bragging about proof raises the bar. If an ad says “clinically proven” or that scientists agree, the seller must have at least that level of support¹.
• Fine print doesn’t fix a cure claim. In another FTC example, an herbal product claims to treat diabetes. A prominent supplement disclaimer on the label doesn’t undo that promise¹.

These rules have teeth. The FTC says it has filed 120 cases challenging supplement health claims over the last decade¹⁰.

In 2022, a settlement order permanently barred two Texas companies and their owner from selling supplements at all. The FTC had alleged that they lacked support for claims that products including Black Garlic Botanicals prevented or treated heart and other diseases¹².

In July 2026, the FTC finalized a settlement with the maker of TruHeight, a height supplement for children and teens, over alleged unsupported growth claims and fake reviews. The company must pay $750,000 of a $4 million judgment¹¹.

When COVID-19 arrived, herbal cure claims came with it

The pandemic was a stress test. By January 2022, the FTC had sent COVID-19 health warning letters to 405 companies and individuals, then warned more than 20 more⁴. The products included supplements, botanicals, herbal remedies, teas and juices⁴.

The FTC said no scientific evidence showed that any of those products could prevent or treat COVID-19⁴. Its letters warned of civil penalties of up to $43,792 per violation under the COVID-19 Consumer Protection Act⁴.

The FDA, working with the FTC, sent its own letters. According to a July 2020 report in the trade publication NutraIngredients-USA, the FDA’s list then had 90 entries, at least 50 of them supplement companies⁵. Four of the seven letters in the latest round involved traditional Chinese medicine products⁵. One seller on the list had a video claiming it was “scientifically proven” that traditional Chinese medicine works against the new coronavirus, the report said⁵.

The herbal industry’s own trade group, the American Herbal Products Association, reviewed 135 FDA and FTC letters sent from March 6 to May 11, 2020, as reported by WholeFoods Magazine⁶. The largest group, 28 letters, involved IV therapy. Eleven involved traditional Chinese medicine, and others covered herbal products, essential oils and colloidal silver⁶. The association’s president said the industry supports enforcement against claims the law doesn’t allow⁶.

The tradition wasn’t the problem. Traditional Chinese medicine has a long history. The problem was claiming proof that didn’t exist, about a brand-new virus, to frightened buyers.

Six phrases to read slowly

The FTC’s 2022 guidance includes examples that map onto everyday herbal marketing¹. This is a decoder built from them.

On the label or ad	What it suggests	What the FTC expects	Ask
“Clinically proven” or “scientifically proven”	Strong trials showed this product works	Proof at the level claimed, for the outcome claimed1	“Which trial, on which product?”
“Clinically tested ingredient”	The tests proved the benefit	Tests must show the benefit; a blend may need its own study1	“Was the finished product tested?”
“Supports immune health”	Fewer colds or infections	Same proof as any health claim; images count1	“Supports how, measured how?”
“Doctor recommended” or “doctor formulated”	Medical experts vouch for it	A qualified expert who examined it, with ties disclosed1	“Which doctor, and paid by whom?”
“Ancient” or “traditional formula”	Centuries of proof	Must match the tradition’s form and dose; never a cure claim for serious disease1	“Is this the same preparation?”
“Approved in Germany” or “European monograph”	A government says it works	Not proof by itself for your product1	“Same extract and dose as the studies?”

A few of these deserve a closer look.

“Doctor recommended.” In one FTC example, an ad says most cardiologists take a vitamin, which implies a heart benefit that needs its own proof¹. In another, an infomercial “doctor” isn’t a licensed physician, hasn’t reviewed the research and is a company officer¹. The FTC says that ad is likely deceptive¹.

“Ancient.” The FTC’s example is a concentrated capsule of an herb traditionally taken as a tea. Even with a note that science is lacking, the claim misleads, because a concentrate isn’t the traditional preparation and may act differently¹. Our article on cultural health stories covers how “ancient” gets invented.

“Approved in Europe.” European herbal monographs are serious documents. But the FTC says a seller citing one still has to check the underlying studies, including whether the dose and form match, and weigh research that disagrees¹.

“Real customers say.” Testimonials aren’t proof under FTC guidance¹. Our article on online reviews covers how to spot fake ones.

How a “clinically proven” study can still fall short

Sometimes there really is a study. The FTC’s guidance shows how it can still miss¹.

• Wrong comparison. In one FTC example, people in a trial improved from where they started. But the placebo group improved too, and the difference between groups wasn’t significant¹.
• A subgroup found later. Slicing the results after the fact, such as looking only at milder cases, isn’t reliable proof¹.
• Real but tiny. Results must be statistically significant and large enough to matter to a person¹.
• A different extract. A botanical extract made a different way, with a different chemical profile, can’t borrow another extract’s trials¹.
• One study alone. No single study stands on its own. A seller has to weigh all the good research, including studies that disagree¹.

Funding is a separate question. Our article on who paid for the study explains how sponsorship shapes results, and our guides to reading abstracts and systematic reviews show how to check a study in minutes.

The five-question claim test

Score each question 0, 1 or 2. This is our tool, built from the FTC principles above.

1. Is it a disease promise? 2 = no disease words or images. 1 = “supports” wording paired with disease cues. 0 = says or implies it treats, cures or prevents a disease, or replaces a medicine.
2. Was this product tested in people? 2 = the same product, dose and form, in randomized human trials. 1 = only an ingredient, a different extract or a different dose. 0 = lab, animal or no studies, or none named.
3. Did it beat a comparison by an amount that matters? 2 = yes, against placebo, by a difference people would notice. 1 = small or unclear. 0 = only before-and-after changes, a subgroup found later, or no comparison.
4. Who’s vouching, and what do they gain? 2 = independent researchers or reviews. 1 = company-funded work or a paid expert, clearly disclosed. 0 = unnamed “doctors,” hidden ties or testimonials only.
5. Does the wider evidence agree? 2 = independent reviews or NIH fact sheets agree. 1 = mixed results or no summaries. 0 = reviews say it doesn’t work, or regulators have flagged the claim.

Reading the total. A score of 8 to 10 means the claim roughly fits the evidence. A score of 4 to 7 means promising but oversold, so if you try it, treat it as a short trial with a stop date. A score of 0 to 3 means hype. Any 0 on question 1 for a serious disease is a reason to report the product, not buy it.

Three made-up labels, scored

These labels are fictional, written for this article. They don’t describe any real brand.

• Label A (fictional): a turmeric-and-ginger joint capsule. The front says “Clinically proven joint relief. Doctor formulated. An ancient secret.” The back cites one eight-week study of 40 people who took a single curcumin extract and reported less pain than at the start. The extract’s supplier paid for the study.
• Label B (fictional): a chamomile and lemon balm bedtime tea. The box says “Traditionally used to help you relax before bed. Not backed by scientific studies.” It also carries the standard note that the FDA hasn’t evaluated the statement. It names no experts.
• Label C (fictional): a bitter-herb tincture. It promises to “reverse diabetes naturally,” says buyers can “ditch your meds,” calls itself “scientifically proven” and shows 10,000 five-star reviews. It names no study.

Question	Label A	Label B	Label C
1. Disease promise?	1 (joint relief hints at arthritis)	2 (relaxation only)	0 (diabetes cure, replaces medicine)
2. This product tested?	1 (one ingredient only)	1 (traditional tea, blend untested)	0 (no study)
3. Beat a comparison?	0 (before-and-after only)	1 (says plainly there’s no proof)	0 (none)
4. Who’s vouching?	0 (unnamed doctor; supplier-paid study)	2 (no paid endorsers)	0 (reviews only)
5. Wider evidence agrees?	1 (assume mixed reviews)	1 (assume a few small studies)	0 (regulators flag such claims)
Total	3: hype	7: modest and honest	0: report it

Notice what won. Label B claims no science at all, yet it scores highest, because its promise is small and its words match its evidence. Label A has a real study, but the study can’t carry the words on the front.

Label C is the dangerous one. The FDA warns that unproven diabetes products can lead people to delay proper treatment⁸, and that people who use them in place of proven therapies may not get the care they need⁷. In 2021, the FDA and FTC jointly warned 10 companies selling supplements that claimed to treat diabetes, noting that such products are unapproved drugs under federal law⁷.

What the evidence behind a claim usually looks like

The FTC says randomized human trials are the most reliable evidence, that lab and animal studies aren’t enough on their own, and that personal stories never are¹. We walk through how common kinds of backing line up with our four evidence levels.

What backs the claim	Example	Evidence level
Several independent randomized trials of the same extract and dose, summarized in a review	A labeled use that matches the trials	Strong evidence
One or two small trials, often company-funded, or trials of a different extract	Label A’s single study	Promising but early
Lab-dish or animal studies, tradition or testimonials alone	Label B’s traditional use; Label C’s reviews	Not enough evidence
Regulators found claims false, trials failed, or harm is documented	Herbal products sold to treat or prevent COVID-194; supplements sold to treat diabetes78	Evidence says no, or unsafe

“Not enough evidence” isn’t a verdict that an herb is useless. It means no one has yet shown that it does what the label suggests.

Asking for proof is a natural-health value

People drawn to natural health often care about honesty, purity and respect for plants. Exaggerated claims work against all three. They teach buyers to distrust herbs that do have good evidence, and they reward the loudest seller over the careful one.

Demanding proof also isn’t anti-industry. The herbal trade’s own association backed enforcement against unlawful COVID-19 claims⁶. Give a supplement ad the same skepticism you’d give a drug ad, and honest sellers win.

How to report a claim that crosses the line

• A false or misleading ad. Report it to the FTC at ReportFraud.ftc.gov⁹. Include screenshots, the product name and where you saw it.
• A product that made you sick. Tell your clinician, then report it to the FDA’s MedWatch program with the online form, the consumer paper form (FDA 3500B), or by calling 1-888-INFO-FDA (1-888-463-6332) and pressing 2¹³.
• A product that says to stop your medicine. Don’t act on the label. The FDA urges talking with your health care provider before using a new product⁸.
• A refund call or email. The FTC says it never asks people to pay money or share account information to get a refund².
• An emergency. Call 911 if someone collapses, has a seizure, has trouble breathing or can’t be woken¹⁴.

Questions readers ask

The bottom line

Herbal marketing has its own dialect, and each phrase makes a specific promise. “Supports” still needs proof. “Clinically proven” needs the level of proof it claims. “Doctor recommended” needs a qualified expert who examined the product, with any ties disclosed, and “ancient” needs to match the tradition it borrows.

Run any claim through the five questions before you pay. Small, honest promises usually beat big, scientific-sounding ones. When a product claims to cure a serious disease or replace your medicine, skip it and report it.

Related reading

• Why supplement labels say ‘supports’ and never say ‘cures’
• Fake reviews became illegal in 2024, yet reviews still mislead you
• Researchers found no ancient jade eggs, a lesson in telling cultural health stories truthfully
• How to read a study abstract in two minutes, including one that spins a failed trial
• Most health products aren’t scams, but many just haven’t been proven

Sources

1. Federal Trade Commission. “Health Products Compliance Guidance.” FTC, December 2022. ftc.gov
2. Federal Trade Commission. “FTC Sends Checks to Consumers Who Bought Certain Products from Golden Sunrise Nutraceutical Between 2017 and 2020.” Press release, February 11, 2026. ftc.gov
3. Federal Trade Commission. “Golden Sunrise Settlement.” FTC refund page, updated May 2026. ftc.gov
4. Federal Trade Commission. “With Omicron Variant on the Rise, FTC Orders More Marketers to Stop Falsely Claiming Their Products Can Effectively Prevent or Treat COVID-19.” Press release, January 2022. ftc.gov
5. Schultz H. “TCM Products Make Up Majority of Recent COVID-19 Warning Letters.” NutraIngredients, July 16, 2020. nutraingredients.com
6. WholeFoods Magazine. “AHPA Analyzes COVID-19 Warning Letters” (American Herbal Products Association, an industry trade group). WholeFoods Magazine, June 17, 2020. wholefoodsmagazine.com
7. U.S. Food and Drug Administration. “FDA and FTC Send Warning Letters to 10 Companies for Illegally Selling Dietary Supplements Claiming to Treat Diabetes.” FDA constituent update, September 9, 2021. fda.gov
8. U.S. Food and Drug Administration. “Questions and Answers: FDA Alerts Companies to Stop the Illegal Sale of Products Claiming to Treat Diabetes.” FDA, content current as of February 10, 2016. fda.gov
9. Lake L. “Health Product Claims and False Guarantees.” FTC Consumer Alert, June 25, 2020. consumer.ftc.gov
10. Federal Trade Commission. “Health Claims.” Truth in Advertising topic page, accessed October 2026. ftc.gov
11. Federal Trade Commission. “FTC Approves Final Order Against TruHeight for Deceptive and Unsubstantiated Advertising of Supplements for Kids and Teens.” Press release, July 15, 2026. ftc.gov
12. Federal Trade Commission. “FTC Finalizes Order Banning Deceptive Marketing by Supplement Seller.” Press release, June 30, 2022. ftc.gov
13. U.S. Food and Drug Administration. “Reporting Serious Problems to FDA” (MedWatch). FDA, content current as of September 26, 2025. fda.gov
14. America’s Poison Centers. “Poison Help” (1-800-222-1222). Accessed October 2026. poisonhelp.org